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crater entombment.!47.148 They recommended that the crater
entombment option be deleted from the EIS and that the contaminated
soil be stored temporarily on Runit while other options for eventual
disposal-were studied by AEC.!49 However, they advised that AEC was
not committed to provide any additional recommendation on the eventual
disposal of contaminated soil and that disposal was a DNA
responsibility. !50
The basic argument presented by proponents of ocean dumping was one
commonly heard: compared to the amount of fong-lived alpha
contamination already dumpedin the ocean, the amount from Enewetak
would be insignificant. The AEC estimated there were only a few hundred
gramsof actual plutonium inall of the contaminated soil of Enewetak, and
that at least a hundred kilograms of plutonium had already been dumped
in the ocean from 1947 through 1974.!5! In other words, the additional
damage that might be done was negligible compared to the possible
damage that had already been done. The counterargument was also
familiar: past damage probably cannot be undone, but any additional abuse
to the system should be stopped completely. DNA continued planning on
crater containment of contaminated soil and debris because this seemed to
be the only option that would be acceptable.
On 14 February 1975, representatives from the action agencies met with
the POD in Honolulu to refine plans for cleanup and rehabilitation.
Conferees included: Mr. Peter T. Coleman, Deputy High Commissioner,
TTPI. Mr. Oscar DeBrum, District Administrator, Marshall Islands, BG
Peel, Division Engineer, POD; Mr. Earl Eagles, HQ DNA: Mr. Tommy
McCraw, Energy Research and Development Administration
(ERDA,.formerly AEC); Mr. Harry Brown, DOI, COL Esser, Field
Command; and Mr. Earl Gilmore, H&N. Much of their discussion
concerned development of POD contracts for the cleanup and
rehabilitation effort. (These were never written due to subsequent
Congressional actions.) More useful discussions were held on the matter
of crater entombment. DNA requested that POD develop a design for the
crater and cost estimates for that part of the project. Also, POD was asked
to provide cost estimates for the complete (Case 5) cleanup which MLSC
desired. DOD and DOItasks in the cleanup and rehabilitation efforts were
reviewed in detail. The conferees also agreed that DNA and ERDA would
develop a much needed Radiological Support Plan. !52
On 24 February
conferr
i
1975,
i
DNA, ERDA, and EPA representatives
i
ically contaminated
materials. ERDA wasable to present its case directly to EPA. No allowance
had been made in the AEC Task Group’s dose assessment for any
radioactivity that might leak from the crater-entombed matrix into the
lagoon or nearby ocean. For this and other reasons, ERDA preferred
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ocean dumping. EPA pointed out that the amount of plutonium which had
already been deposited in the lagoon and wascirculating in its waters was
probably much greater than any that might leak from the crater. !53.!54 In
fact, there was a far greater amount of fallout in the lagoon than there was
left on the islands to be cleaned up. The lagoon had a far greater area than
the islands, and material from the islands tended to be washed into the
lagoon.
EPA described the measures necessary to obtain a permit in the unlikely
event the plutonium contamination could be considered something other
than ‘‘material in any form produced for radiological warfare purposes.”
The criteria for issuance of a permit were summarized as: (1)
establishment of a need to dump; (2) lack of an alternative means of
disposal; (3) definition of the potential damage that could result to the
marine environment; and (4) the effect of the proposed dumping on other
users of the area. Permits could be granted only for an approved dump site.
Obtaining approval for a dumping site required selection of a definite site,
a survey of the dumping area (including the benthic community) and the
ocean currents, and definition of the monitoring process to be used while
the dumping is carried out. A minimum of 4 months would be required
after receipt of a properly executed application before final action could be
expected from a request to EPA. Involved in the process was the
requirement for a public notice of 30 days and then a public hearing 30
days after publication of the public notice, followed by allowance of
another 30 days for the EPA hearing officer to reach a finding. No
assurances could be provided that the finding would not be adverse,
particularly if any controversy existed. If the DEIS identified another
feasible disposal method, it would virtually eliminate one of the
requirements for an ocean-dumping permit, namely the lack of an
alternative disposal method.
The ERDA representative contended that EPA was overly conservative
in applying the United States ocean-dumping law, since the International
Ocean-Dumping Agreement would permit other countries to dump quite
large amounts of long-lived alpha contamination. EPA countered that the
United States law, which predated the international agreement, was based
on the philosophy of preventing further pollution rather than facilitating
cleanup and disposal of radiological contamination resulting from a past
event. Public laws and EPA regulations did not envision a disposal effort of
the magnitude of the Enewetak radiological cleanup and provided no
Cobb
ERDA representatives responded that, while ERDA had several test
sites which someday must be decontaminated, ERDA had no intention of
adopting ocean dumping for those wastes. However, there was
considerable concern that, if crater containment was used, ERDA would